JA FAR Part 8.final SIGNED.pdf

LIMITED SOURCE JUSTIFICATION UNDER ORDERING PROCEDURES FOR FEDERAL SUPPLY

SCHEDULE IN ACCORDANCE WITH FEDERAL ACQUISITION REGULATION (FAR) 8.405-6(a)(1)(C)

“logical follow-on to an original Federal Supply Schedule order”

On the basis of the following justification, I, Corey Mann, hereby approve the use of a limited source proposed contractual action pursuant to the authority of FAR 8.405-6(a)(1)(C), In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited Source Justification”

The U.S. Department of Veterans Affairs Contracting Office Strategic Acquisition Center (SAC) Frederick proposes the use of a limited source justification for Talent Management System (TMS) sited eLearning Clinical Certification Training Module Updates under FAR 8.405- 6(a)(1)(C), in the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order placed in accordance with the applicable Federal Supply Schedule competitive ordering procedures.

2. The nature and/or description of the action being approved.

This action will support updates to four previously developed eLearning Training modules designed to provide necessary content for Clinician certifications required by VA to administer medical disability evaluations (MDEs).

This requirement will update the specified modules developed and produced on a prior effort by Oak Grove Technologies. The requirement seeks to combine two of the four modules into one (final delivery will provide 3 updated modules). The work includes review and analysis of current content against mandated changes, creative and design tasks to update content as required, development of the storyboards, alpha, beta and final stages, and delivery of updated modules.

An aggressive timeline for completion of the deliverables is an essential element to success of the project. Although this action was planned for FY2020, due to the global pandemic and obvious disruptions to the normal flow of business brought on by the COVID-19 outbreak, a decision was made to postpone seeking the needed updates until FY2021 with the intention of awarding the services as quickly as possible. Given the current delay in providing updates for the certification trainings, the customer fears that Clinicians are not able to use the most up to date criteria when assessing the examination findings for individual Veterans. In order to provide the most accurate assessments of the MDE findings and avoid improper or incomplete conclusions that could have a direct and negative impact on countless Veterans, EES seeks to award this logical follow on action to Oak Grove Technologies, Inc.

Limited Sources Justification – FAR Part 8 – OAK Grove Technologies

3. The authority and supporting rational

The following is documentation for the basis of restricting consideration to one vendor.

The VHA performs nearly three million Department of Veterans Affairs (VA) medical disability examinations (MDEs) yearly. The quality assurance program of the Office of Disability and Medical Assessment (DMA), as well as reports from VA’s Office of the Inspector General (OIG), have revealed variations among the Veterans Integrated Service Networks (VISNs) in the performance and quality of VA disability examination reports. As a result, VHA and Veterans Benefits Administration (VBA) determined there is a need for updates to the training and certification program for all clinicians performing VA MDEs due to recent modifications to the criteria used to perform and assess disability examinations.

VA’s Employee Education Service (EES) has been collaboratively working with DMA for over twelve years to develop, maintain and update the certification training modules. Oak Grove Technologies has already developed and produced the four (4) eLearning modules identified as requiring updates. The fact that relationships between the vendor, program Subject Matter Experts (SMEs), and clinical practitioners provides a logical and necessary support structure ensuring the successful and timely delivery of the update requirements.

With respect to economy and efficiency, it is imperative that VA’s EES complete this requirement as soon as practicable. The current assessment and evaluation paradigms are shown to be inadequate to provide consistency in ratings throughout the VHA service networks. In order to avoid the possibility of incomplete or ineffective ratings being assessed for individual Veteran’s disability examinations these services and their timely delivery should be considered as imperative. The added costs to the Government, combined with the additional time needed to complete a full and open competition would surely delay implementation of any changes to the eLearning content, and could have a continuing and negative impact on Veterans assessment ratings. It should be noted that the requirement was initially sought by EES beginning in FY 2020, but due to the impact of COVID-19, resulting in mandatory telework, the inability to meet face to face, and other various procedural changes, the service found it nearly impossible to plan and execute a procurement. For that reason, it was delayed until the 2nd quarter of FY 2021.The program office has provided an estimated cost for the requirement of $149,965.95 for one (1) 12-month period of performance. The estimate was developed using pricing consistent with the FSS price list associated with Oak Grove Technologies FSS award.

In order to avoid continued delays in updating the certification training requirements the contracting officer determined the use of sole source contract with one (1) 12-month base period to be in the best interest of the Government. Because Oak Grove Technologies, Inc.

previously provided these services to the VA, they are the best choice considering experience, subject matter expertise, the lack of ramp up time required, overall savings to the taxpayer, and the anticipated timely delivery of all requirements, it is determined that use of the authority

Limited Sources Justification – FAR Part 8 – OAK Grove Technologies cited will provide for economy and efficiency to the Government while having a positive and direct impact on our Veterans.

The CO determines that use of a limited source justification to facilitate eLearning updates to four TMS DME certification training modules under FAR 8.405-6(a)(1)(C) and award a 12-month task order to Oak Grove Technology, Inc. is in the best interested of the Government.

4. Approvals

Contract Specialist:

Thomas Evans

Contracting Officer:

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Corey Mann

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO Thomas Evans, Contract Specialist, at thomas.evans3@va.gov.

mailto:thomas.evans3@va.gov